We have translated 6 more CRA interpretations

4 September 2023 - 11:13pm
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We have translated 6 further CRA interpretations released in January of 2003 and December of 2002. Their descriptors and links appear below.

These are additions to our set of 2,571 full-text translations of French-language Technical Interpretation and Roundtable items (plus some ruling letters) of the Income Tax Rulings Directorate, which covers all of the last 20 ¾ years of releases of such items by the Directorate. These translations are subject to our paywall (applicable after the 5th of each month).

Bundle Date Translated severed letter Summaries under Summary descriptor
2003-01-10 23 January 2003 External T.I. 2002-0161405 F - COUT DE TRANSPORT DU CONJOINT Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(a) presence of employee’s spouse at the special work site would not be decisive of their off-site home not being the employee’s “principal place of residence”
Income Tax Act - Section 6 - Subsection 6(6) - Paragraph 6(6)(b) transportation costs could include those of a spouse staying with the employee at the special work site
2003-01-03 14 January 2003 External T.I. 2002-0154205 F - CARACTERE RAISONNABLE FRAIS Income Tax Act - Section 67 reasonableness of management fees determined by reference to what would be paid a 3rd party
2002-12-20 3 January 2003 External T.I. 2002-0141745 F - Terminaison d'une Fiducie testamentaire Income Tax Act - Section 249 - Subsection 249(1) - Paragraph 249(1)(b) testamentary trust ceases to exist when all its assets have been distributed
10 January 2003 External T.I. 2002-0143315 F - FRAIS LEGAUX DEDUCTIBILITE Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Start-Up and Liquidation Costs estate could deduct damages incurred in the course of business of the deceased
Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(a) - Legal and other Professional Fees estate could deduct legal fees paid by it regarding damages incurred in the course of business of the deceased
7 January 2003 External T.I. 2002-0173245 F - REMBOURSEMENT DEPENSES ET ALLOCATIONS Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) no benefit on reimbursement of snacks provided to clients
6 January 2003 External T.I. 2002-0173405 F - Capital Dividend Account Income Tax Act - Section 89 - Subsection 89(1) - Capital Dividend Account - Paragraph (a) application of transitional rules re changes in inclusion fraction including example